1887

United Nations Manual for the Negotiation of Bilateral Tax Treaties between Developed and Developing Countries

image of United Nations Manual for the Negotiation of Bilateral Tax Treaties between Developed and Developing Countries
The Manual for the Negotiation of Bilateral Tax Treaties between Developed and Developing Countries provides a guide to all aspects of tax treaty negotiation, including a brief description of the Articles of the United Nations Model Double Taxation Convention between Developed and Developing Countries. It is intended mainly for negotiators with little or no experience in the negotiation of tax treaties.

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Improper use of treaties

Taxpayers may, from time to time, seek to obtain benefits from treaties in ways that were not intended by the two countries. For example, a resident of State A may seek to take advantage of lower withholding rates on royalties provided by State B under its treaty with State C, by structuring contracts through an intermediary in State C.

English

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